E-invoicing in Europe

E-invoicing mandate in place? Yes

Timeline and status: Start date by 1 January 2014.

Who is concerned? Suppliers of federal agencies, including foreign companies with a permanent establishment in Austria. Foreign non-established companies are obliged to issue and transmit e-invoices to the extent technically possible.

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E-invoicing mandate in place? Yes

Timeline and status: Implementation dates by region: Flanders, as of 1 January 2017; Brussels, by 1 November 2020; Wallonie, by 1 January 2022.Implementations schedule nationwide: New regulation expands the e-invoicing requirement nationwide. The implementation schedule of this mandate requires Suppliers of public bodies to issue electronic invoices, based on the combination of (a) the publication date of the tender and (b) the value of the contract with the public body, excluding VAT, as follows:- Contracts equal to or greater than EUR 215,000: the obligation applies to invoices related to tenders published from 1 November 2022 on.- Contracts equal to or greater than EUR 30,000: the obligation applies to invoices related to tenders published from 1 May 2023 on.- Contracts below EUR 30,000: the obligation applies to invoices related to tenders published from 1 November 2023.- Remark: Contract values below EUR 3,000 are exempt from the e-invoicing obligation.

Who is concerned? Suppliers of the public administrations. It also applies to foreign VAT-registered companies (not explicitely excluded).

E-invoicing mandate in place? No

Timeline and status: There are discussions to implement mandated e-invoicing both in B2G and B2B. Also, SAF-T reporting is under development.

E-invoicing mandate in place? Yes

Timeline and status:  Mandatory issuance of structured e-invoices for suppliers to public administrations as of 1 July 2019.

Who is concerned? Suppliers to public administrations. It also applies to VAT-registered foreign companies.

Additional comments: Concerning foreign companies, all international exchange of e-invoices takes place through the PEPPOL (Pan European Public Procurement OnLine) network, which enables the cross-border exchange of electronic invoices and other documents in public procurement processes. Fina (Croatian e-invoicing system) has established an access point within the PEPPOL network and all public procurement obligees who are registered in the central register - the e-Account service platform for the state, are recognizable and accessible to foreign suppliers through this access point.

E-invoicing mandate in place? No

Timeline and status: Public administration must accept e-invoices. Under review to introduce mandatory B2G e-invoicing.

E-invoicing mandate in place? No

Additional comments: Public bodies must accept e-invoices. No mandate B2G or B2B.

E-invoicing mandate in place? Yes

Timeline and status: Since 2005, suppliers of services and goods are required to send electronic invoices (UBL) to public institutions and public authorities.

Who is concerned? Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded).

Additional comments: The Danish government mandates the use of the NemHandel platform for exchanging e-invoices in B2G public procurement.

E-invoicing mandate in place? Yes

Timeline and status: Since July 2019, suppliers of services and goods are required to send electronic invoices to public institutions and public authorities.

Who is concerned? Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded).

E-invoicing mandate in place? Yes

Timeline and status: Since 6 April 2021, suppliers of services and goods are required to send electronic invoices to public institutions and public authorities.

Who is concerned? Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded). If the sender does not have the capability to send EN-compliant e-invoices, a bilateral agreement can be set between the two trading partners.

E-invoicing mandate in place? Yes

Timeline and status: The general start date of the mandate was 1 January 2020 (gradual implementation from January 2017 to January 2020).

Additional comments: Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded). Invoices issued by foreign service providers fall within the scope of Chorus Pro as long as the service falls under French public procurement legislation.

E-invoicing mandate in place? Yes

Timeline and status: Start date: all suppliers to Federal authorities since 27 November 2020. The different German states (16) have implemented differently the e-invoicing obligation. If required, you should check the regulations concerning contracts with a particular German state.

Who is concerned? Suppliers to public authorities. It also applies to VAT-registered foreign companies (not explicitly excluded).

E-invoicing mandate in place? Yes

Timeline and status: The obligation started by 12 September 2023 and will be completed by January 2025, with the mandate to issue e-invoices to all the general state administrative bodies as follows:

- By September 2023, for contracts concerning the Ministries of Infrastructure and Transport, Digital Governance, Immigration and Asylum, the Municipality of Athens, the National Central Authority for Health Procurement (E.K.A.P.Y.), the National Central Procurement Authority of Ministry of Development and Investments, the Information Society S.A., the Athens University of Economics, "Attiko Metro S.A.", EYDAP S.A. and Egnatia Odos SA.

- By January 2024, for contracts concerning bodies of the rest of the Central Administration.

- By July 2024, for contracts concerning other bodies or authorities.- By January 2025, businesses must issue e-invoices for all other expenses of the General Government invoiced from that date.

Who is concerned? Suppliers to public authorities. It also applies to VAT-registered foreign companies (not explicitly excluded).

Additional comments: Generally, public contracts or expenses up to EUR 2,500 do not fall within the obligation to issue an electronic invoice. The mandate also excludes contracts in the fields of defense and security, low-value public contracts, certain public contracts between public sector entities, certain contracts between contracting authorities, certain contracts concession between public sector entities. Find more information here.

E-invoicing mandate in place? No

Timeline and status: Public bodies must accept e-invoices, but no mandate B2G or B2B.

Additional comments: Real-time reporting obligation is in place in Hungary. Learn more.

E-invoicing mandate in place? No

Timeline and status: Public bodies must accept e-invoices, but no mandate B2G or B2B. Find official notice here.

E-invoicing mandate in place? Yes

Timeline and status: B2G eInvoicing is mandatory since 2014 (2015 for sub-central administrations).

Who is concerned? Mandatory for economic operators established or resident in Italy issuing invoices to Italian government departments. Non-Italian economic operators can issue invoices in paper or electronic form.

E-invoicing mandate in place? In progress.

Timeline and status: Latvia plans to make e-invoicing mandatory both for B2G transactions by January 2025. Draft regulation needs to pass final approval.

E-invoicing mandate in place? Yes

Timeline and status: Lithuania made B2G eInvoicing mandatory in July 2017, although from 8 April 2019, all suppliers to public contracting authorities are obliged to issue only EN-compliant eInvoices namely Peppol BIS Billing 3.0.

Who is concerned? Public entities’ suppliers are required to send electronic invoices in the context of public procurement. It also applies to VAT-registered foreign companies. If a natural/legal person operating in the European Union has won the public procurement, they have the opportunity to submit invoices that meet the EU electronic invoice standard through the PEPPOL network.

E-invoicing mandate in place? Yes

Timeline and status: Mandated B2G e-invoicing applies since March 2023. This requirement was implemented gradually, according to the following deadlines:

- First, large businesses by 18 May 2022.

- Secondly, medium-sized businesses by 18 October 2022.

- Finally, the rest of the businesses by 18 March 2023.

Who is concerned? This obligation concerns national and foreign economic operators, suppliers of public bodies.

E-invoicing mandate in place? Yes

Timeline and status: The mandate applies to all contracts with a start date from 1 January 2017 onwards concerning the Dutch central government. The municipalities are not legally required to ask for electronic invoices from their suppliers. However, they have the possibility to set a requirement in their procurement contracts based on bilateral agreements.

Who is concerned? All suppliers to the Dutch central government. It also applies to VAT-registered foreign companies (not explicitly excluded). Suppliers to other public organizations other than the central government must check with those organizations the requirements in place in terms of e-invoicing.

E-invoicing mandate in place? Yes

Timeline and status: Since 2 April 2019, it has been mandatory for all public contracting authorities to receive and process electronic invoices. In 2012, it became mandatory for the suppliers of central government entities to issue e-invoices.

Who is concerned? Public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded).

E-invoicing mandate in place? No

Timeline and status: Economic operators are not required to submit e-invoices to public bodies.

E-invoicing mandate in place? Yes

Timeline and status: Start date: January 1, 2021 for large companies; and January 1, 2024 for Micro, small and medium companies.

Who is concerned? Public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded).

E-invoicing mandate in place? Yes

Timeline and status: B2G e-invoice implemented since 2020.

E-invoicing mandate in place? Yes

Timeline and status: Start date was May 2022.

Who is concerned? The mandate impacts all suppliers in the public sector. Find more information here.

E-invoicing mandate in place? No

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E-invoicing mandate in place? Yes

Timeline and status: Mandate applies since 2015.

Who is concerned? Public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded).

E-invoicing mandate in place? Yes

Timeline and status: Mandate applies since 2015

Who is concerned? Generally speaking, all public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded). The obligation to issue an e-invoice depends on the specific public authority acting as contracting party. There are two scenarios of exceptions to issue an e-invoice, and it is up to the particular public administrations and implementing regulation to implement it or not: i) the value of the invoice is up to EUR 5,000, and ii) only temporarily, when there is a service invoice issued involving public administrations abroad.

E-invoicing mandate in place? Yes

Timeline and status: The mandate applies since 1 April 2019.

Who is concerned? Public entities’ suppliers are required to send electronic invoices to all public sector contracting authorities. This refers to contracts subject to Public Procurement Act (LOU), the Act on Procurement in the Utilities Sectors (LUF), the Defence and Security Procurement Act (LUFS) and the Concession Procurement Act (LUK). It also applies to VAT-registered foreign companies (not explicitly excluded).

E-invoicing mandate in place? Yes

Timeline and status: The mandate applies since 1 January 2016 for the Federal administration in contracts over CHF 5,000.

Who is concerned? Public entities’ suppliers are required to send electronic invoices. Not applicable to foreign companies.

Additional comments: Foreign suppliers: You can create your invoices with an Office application (e.g. Word, Excel) or with a straightforward accounting or invoicing program. Create the invoice as a PDF file and email it directly to the Federal Administration: Pdf-rechnung@efv.admin.ch.

E-invoicing mandate in place? Yes

Timeline and status: Currently, it is only mandatory in the public health sector.